Spoils: Foreign Supplier Verification Advisory

Spoils: Foreign Supplier Verification Advisory

Incidents of water damage leading to potentially fungus-tainted coffee are not limited to overseas. This example shows coffee damaged in US coffee warehouses.

By Dan Bolton

The government of Uganda this fall took the unusual step of ordering the closure of 95 coffee processing factories in the Kayunga District – a response to concerns that rain-damaged coffee could result in export bans. Victor Yawe, quality control officer at the Uganda Coffee Development Authority said all factories built with timber and iron sheets and those built in wetlands “pose a risk of contamination.”

The impact of this news item may seem distant but the foreign supplier verification program (FSVP) is now law for the largest US companies and in March 2019 will include all firms earning $1 million or less. Every US commercial import exceeding $2,500 must be recorded in the automated commercial environment/international trade data system (ACE/ITDS) database. FDA is only beginning to enforce the new law, which empowers FDA to take proactive steps to prevent the sale, distribution, and consumption of tainted food products. Uganda and all other coffee, spice, and tea suppliers are wise to take precautions now.

FSVP compliance

“At origin, there are relatively inexpensive ways to reliably and accurately measure brix, moisture, and water activity. Depending on their level of engagement, roasters may choose to partner with producers directly to manage quality and monitor possible contamination,” advises Spencer Turer, v.p. at Coffee Enterprises in Hinesburg, Vermont.

“FDA requires importers perform certain risk-based activities to verify that coffee and tea imported into the US has been produced in a manner that meets applicable US safety standards,” Turer explains. FDA’s preventative controls for human food specifies that a trained PCQI (preventive controls qualified individual) develop and apply a food safety plan – meaning roasters shall use a PCQI to determine their level of risk and develop a plan that includes hazard analysis (biological, chemical, and physical hazards). Preventatives controls include process controls, food allergen controls, and sanitation. Lastly, roasters are required to have a comprehensive recall plan, he said.

The key to compliance is the individual identified as the FSVP importer. This cannot be a company. It must be an individual responsible for the FSVP plan. It could be an employee charged with food safety, a hired broker or an independent importer reselling the products. Regardless of affiliation, that individual must own the product at the time of entry. It is mandatory this individual create an FSVP plan and keep any foreign suppliers in compliance.

A lot of companies do not want the responsibility of making sure the arriving food products are safe. In these instances they need to let someone else import it so that the product is already in the US before they buy it.

Export concerns

And it is not just exports to the US that are getting additional scrutiny. In January Pakistan adopted more stringent testing for aflatoxins, a group of metabolites from Aspergillus fungus that is commonly seen in grains. It can also be found in some tea, such as puer. Such toxins could prove fatal so when a shipment of tea from Kenya was discovered to contain aflatoxin, Pakistan required all imports to be tested. Exports plummeted from more than 24 million to 12 million kilos as shipments slowed. A reversal on the testing requirement led to the resumption of imports a month later.

Caffeine inhibits production of aflatoxins from mold. Moisture levels of dry tea are generally around half of what is needed to grow mold. Tea producers include a "kill-step" (drying) to reduce moisture to around 3-5%. Imports arrive at US packers with a moisture content between 6-7% (general industry standard). Tea above a threshold of 10-11% moisture would be rejected under food safety guidelines.

Mold growth needs around 15% moisture in the tea. Consequently occurrences of aflatoxins from Aspergillus are very, very rare, according to food safety experts.

Of primary concern to anyone scoping their “FSMA Risk Analysis” is to ensure tea is free from pathogenic bacteria, which thankfully are also rare on tea. Precautionary, pre-shipment testing of such pathogens is routine and positive results extremely rare indeed (<0.1%). Tea is a very low risk product because of all this care being taken. If one peruses the FDA databases, there are zero causes of illness or death from Camellia sinensis products imported into the USA."

FDA recognizes the enormity of the task and has enlisted organizations to assist companies in complying. In August, the American National Standards Institute (ANSI), coordinator of the US voluntary standardization system, accredited the first third-party certification body recognized under FSMA.

A release states that ANSI accreditation supports those seeking FSMA compliance with the foreign supplier verification program and predicted many more food safety specialists will be certified.

CORRECTION: The original work did not make it sufficiently clear that the presence of harmful toxins or bacteria in tea is very, very rare.